How PropComply Performs Customer Due Diligence
Why this matters
Customer Due Diligence is the operational core of any AML programme. Weak CDD is the most common finding in Spanish AML inspections.
CDD performed inconsistently across clients and team members creates audit risk and slows down transactions.
Practical implementation
Identification
Collect government-issued identity documents for natural persons and full corporate documentation for legal entities, including the chain of ownership.
Verification
Verify the identity using independent and reliable sources — for example document authenticity checks, biometric liveness, or qualified electronic identification.
Beneficial ownership
Identify the natural persons who ultimately own or control the client, applying the 25% threshold and capturing the full ownership chain.
Purpose of the relationship
Document why the client is entering into the transaction — buy-to-live, investment, relocation, or business activity.
Ongoing monitoring
Re-screen, re-verify and re-assess risk at meaningful trigger events: new transaction, change of ownership, adverse media.
How PropComply helps
- Structured digital onboarding link sent to the client — no manual document chasing.
- Automated document checks combined with PEP, sanctions and adverse-media screening.
- Beneficial ownership capture for companies, trusts and complex structures.
- Versioned client file with full change history.
PropComply supports — but does not replace — professional judgement, and does not guarantee AML compliance. Each obligated subject remains responsible for its own AML decisions.
Practical example
A Spanish SL purchasing through a corporate structure
A Spanish SL owned by a foreign holding company makes an offer on a commercial property in Málaga.
PropComply collects identity documents for the legal representative, corporate documents for both entities, and identifies the ultimate beneficial owner behind the holding structure.
The file is screened, risk-rated as medium, and stored as a single structured profile that can be shared with the seller's lawyer.
Best practice
- ·Standardise CDD requirements per client type and risk level.
- ·Never accept beneficial ownership claims without supporting documentation.
- ·Refresh CDD at defined intervals — risk does not stand still.
- ·For complex structures, consider engaging CostaAML Compliance for advisory support.
Related guides
Beneficial Ownership Verification
Identifying the natural persons behind companies, trusts and legal entities involved in real estate transactions.
Enhanced Due Diligence in Practice
How higher-risk clients should be handled and how PropComply supports Enhanced Due Diligence in real estate transactions.
PEP & Sanctions Screening Workflow
How PEP, sanctions and adverse media screening is integrated into onboarding — and why ongoing screening matters.
AML File Management & Record Keeping
How AML documentation should be organised, stored and retained across the client lifecycle.
Need help implementing your AML framework?
CostaAML Compliance provides AML implementation, training, documentation and regulatory support for Spanish real estate professionals.
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